The firm’s tax attorneys analyze, structure and negotiate tax-efficient solutions for our clients’ complex business transactions. We have significant experience in planning all tax aspects of business formation, ongoing operations and organic transactions, including stock or asset acquisitions and divestitures, and internal restructurings.
We use our extensive knowledge and experience of sophisticated structuring techniques to maximize value for our clients. In some cases, this means achieving tax-deferral for our clients when desirable (e.g., through tax-free reorganizations, spin-offs and UPREIT transactions), and, in others, it means discovering and legally extracting latent tax value from transactions that otherwise would leave cash on the table for revenue authorities.
The group zealously protects its clients’ tax interests in negotiating with their transactional counterparties, anticipating potential administrative challenges to tax positions and complying with the tax-related aspects of legal disclosure obligations. Our attorneys have requested and obtained numerous private letter rulings from the IRS in order to safeguard the tax treatment of specific transactions, and we have often provided tax opinions in connection with structuring large, complex transactions in which it is not practically feasible to seek an advance ruling from the IRS.
Similarly, we ensure that our clients comply with tax-related disclosure obligations (under the securities laws) in the context of public and private debt and equity offerings and other transactions, including in the preparation of prospectuses for numerous private equity and hedge funds.
We also advise clients on a variety of international business activities and tax matters, including both the taxation of foreign entities and individuals in the U.S., as well as the taxation by the U.S. of the foreign operations of U.S.-based businesses and residents. The firm’s international tax practice encompasses a wide variety of transactions, including: overseas business structures for start-up operations and acquisitions to maximize the beneficial tax use of losses and opportunities for deferral of U.S. taxation on foreign earnings, and to minimize U.S. taxation on transfers outside the U.S.; financings, foreign reorganizations and divestitures; and joint venture arrangements involving both foreign and domestic entities.
Additionally, the group counsels clients often on highly complex and specialized federal tax rules applicable to U.S.-based businesses operating internationally, including issues related to transfer pricing, tax treaties, foreign tax credits, controlled foreign corporations and passive foreign investment companies.